G.R. No. 157975 , June 26, 2007
Philippine Transmarine Carriers, Inc. vs. Felicisimo Carilla

FACTS

Petitioner Philippine Transmarine Carriers, Inc., a manning agent, hired respondent Felicisimo Carilla as Master of MV Handy-Cam Azobe under a 12-month POEA-approved contract. On June 6, 1994, while the vessel was in Bombay, India, respondent was dismissed and repatriated to the Philippines. Respondent filed a complaint for illegal dismissal before the POEA, claiming he was terminated without notice, hearing, or valid cause. He sought payment of salaries for the unexpired portion of his contract, unremitted allotments, and accrued leave pay.
Petitioner countered that respondent’s dismissal was for a just cause, alleging his incompetence and negligence led to several maritime incidents causing substantial cargo damage and vessel repairs. Petitioner presented documents, including a “Logs of Events” summary and Senior Officer Evaluation Reports, to substantiate its claim of respondent’s poor performance warranting termination.

ISSUE

Whether the Court of Appeals committed reversible error in affirming the findings of the Labor Arbiter and the NLRC that respondent was illegally dismissed.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic rests on the fundamental principle that in termination cases, the burden of proof rests upon the employer to show that the dismissal was for a just or authorized cause. Petitioner failed to discharge this burden. The documentary evidence it presented, the “Logs of Events” and the evaluation reports, were correctly found by the labor tribunals to be unauthenticated, self-serving, and unreliable. These documents lacked the requisite probative value as they were not the official vessel logbook and were prepared by parties interested in the outcome of the case.
The Court emphasized that the assessment of the credibility of evidence is primarily within the domain of the Labor Arbiter and the NLRC, whose factual findings are accorded respect and finality when supported by substantial evidence. No grave abuse of discretion was found in their uniform conclusion that petitioner did not substantiate its allegation of respondent’s incompetence with clear and convincing evidence. Consequently, the dismissal was deemed illegal. The awards for the monetary value of the unexpired portion of the employment contract and other benefits were upheld, subject to the applicable rule on the computation of such awards under the prevailing law.